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Belgium
EU Commission calls out harmful tax practices in Belgium, Cyprus, Hungary, Ireland, Luxembourg, Malta, Netherlands
The EU Commission took tentative steps toward reducing harmful tax competition among EU member countries today, publishing European Semester country reports that identify seven EU countries as potentially facilitating tax avoidance by multinationals. The Commission today also released a taxation paper detailing economic evidence that suggests that particular tax avoidance structures , , ,
Americas
Companies face setback in challenge to District of Columbia’s use of Chainbridge transfer pricing method
Mark Nachbar and Mary Bernard of Ryan, LLC note the release of a surprising January 26 ruling in actions, brought by Hess, Exxon, and Shell, challenging the District of Columbia’s use of transfer pricing software developed by Chainbridge Software to assess millions in tax liabilities against them . . .
Belgium
Asia-Pacific
India revises transfer pricing safe harbors providing tax relief to multinationals
India transfer pricing specialist Ajit Jain discusses the government’s June 7 decision to add a new transfer pricing safe harbor for low-value adding intragroup services and reduce existing safe harbor margins for knowledge process outsourcing services, contract research and development services, and other services.. . . .
Featured News
The new OECD/G20 guidance aligning transfer pricing outcomes with value creation: upending international contract law
US international transfer pricing attorneys Robert Feinschreiber and Margaret Kent discuss guidance developed during the OECD/G20 base erosion profit shifting (BEPS) project which applies transfer pricing concepts to contracts. . .
Europe
Switzerland: corporate tax reform III fails
Corporate tax reform III was rejected by popular referendum today, with 59.1 percent of the population voting against the Swiss government proposal, writes MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne . . .
Austria
Switzerland, Austria to terminate withholding tax agreement
Davide Anghileri of the University of Lausanne discusses Switzerland and Austria’s November 11 agreement to terminate their withholding tax agreement . . .
Council of the EU
EU plan could exclude countries with zero corporate rate from tax haven blacklist
EU finance ministers today agreed to criteria to be used to identify non-EU countries as candidates for an EU-wide tax haven blacklist which could result in countries that have low or even zero corporate. . .
Europe
Netherlands proposes further limits on private equity investor interest deductions
International tax experts, Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze a proposed Netherlands tax law that would tighten rules designed to prevent excessive leveraging of acquisitions of Dutch companies by private equity investors . . .
Featured News
Business seeks greater role in crafting multilateral instrument to implement BEPS tax measures
The OECD on July 4 released 33 comment letters received in response to its discussion draft on the development of a multilateral instrument to implement the tax treaty provisions in the final OECD/G20 base erosion profit shifting (BEPS) plan reports. All the comment letters released, except for one, submitted by the BEPS Monitoring . . .
Americas
Florida and Delaware LLPs and LLLPs to be taxed as corporations, Canadian tax officials say
Kabir Jamal, an attorney with Goodmans LLP, Toronto, discusses statements made by Canadian Revenue Agency officials at a conference last week announcing the agency’s decision to classify Florida and Delaware LLPs and LLLPs as corporations for income tax purposes . . .
Europe
EU proposal requiring multinationals to publicly disclose tax information disputed by business, NGOs
Large multinational corporations operating in Europe would be required to publicly disclose tax information on a country-by-country basis under an EU Commission proposal, unveiled April 12, which is already drawing criticism from both . . .
Europe
Europe
Europe
Italian Supreme Court rejects Luxembourg company tax appeal, finds parent-subsidiary directive inapplicable
Gian Luca Nieddu of Hager & Partners, Milan area, discusses a recent Italian Supreme Court decision rejecting an Italian corporation’s request for reimbursement of withholding taxes paid on dividends distributed to its Luxembourg parent; the author argues that the opinion is based on faulty reasoning . . .
Americas
Americas
Americas
Asia-Pacific
Americas
Americas
US disputes need for special digital economy tax rules, seeks consensus on profit allocation issues
The highly-anticipated interim report of the Task Force on the Digital Economy (TFDE), slated for release in April, will state that countries are divided on a long-term solution for taxing the digital economy, with the US arguing that there is no need for special tax rules in this area, said Chip Harter, Deputy Assistant Secretary (International Tax Affairs) at the US Department of the Treasury. Speaking in Washington at a Tax Council Policy Institute conference held . . .
Asia-Pacific
Singapore budget introduces GST on imported digital services, promotes nation’s role as financial and innovation hub
Eugene Lim of Providence Law Asia, LLC, discusses Singapore’s highly-anticipated Budget 2018, released today, which includes a goods and services tax (GST) rate hike, a new GST levy on imported digital services and carbon tax, and new tax rules aimed at strengthening Singapore’s role as a financial and innovation hub . . .
Americas
US Republican tax reform plan would rewrite international tax system
US House Republicans today presented their long-awaited tax reform bill, proposing to dramatically change the US international tax system.As expected, the Republican proposal includes a move to a territorial tax system accomplished by a foreign dividends received deduction. This is coupled with a deemed repatriation of existing earnings held offshore. The bill sets the deemed . . .
Europe
Europe
Court voids French law denying withholding tax exemption for dividends paid outside EU
Davide Anghileri of the University of Lausanne discusses an EU Court of Justice ruling, delivered September 7, which concludes that France violated EU law when it applied a general antiabuse rule to deny a withholding tax exemption for dividends distributed by a resident subsidiary to a company controlled by a resident of a non-EU State . . .
Asia-Pacific
Feedback sought in review of 8 countries’ tax dispute resolution processes
The OECD on June 9 asked multinational firms to provide feedback regarding their experiences with the tax dispute resolution processes in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain. The eight countries’ mutual . . .
